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EPA OIG Not Fully Compliant

With OIG Policy on Time and 

Attendance Reporting 

Report No. 15-B-0074 February 4, 2015

U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF INSPECTOR GENERAL

Spending Taxpayer Dollars
Report Contributors: Leah Nikaidoh

Lela Wong

Abbreviations

EPA U.S. Environmental Protection Agency

FMFIA Federal Managers’ Financial Integrity Act

FY Fiscal Year

IGEMS Inspector General Enterprise Management System

OCOS Office of Chief of Staff

OIG Office of Inspector General

OMS Office of Mission Systems

PPL PeoplePlus

TAAP Time and Attendance Approval Processing 

Are you aware of fraud, waste or abuse in an

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15-B-0074

February 4, 2015

Why We Did This Review

On August 27, 2013, a member 

of the Senate Committee on 

Environment and Public Works 

requested that the 

U.S. Environmental Protection 

Agency (EPA), Office of 

Inspector General (OIG), initiate 

work in connection with fraud 

committed by John C. Beale, a 

former Senior Policy Advisor 

with the EPA’s Office of Air and 

Radiation. One of the areas that 

we reviewed was the EPA’s and 

OIG’s time and attendance

process. This report addresses 

the OIG’s compliance with its 

timekeeping policy regarding 

use of the Inspector General 

Enterprise Management 

System (IGEMS).

This report addresses the 

following OIG goal:

 Be responsible stewards of

taxpayer dollars.

Send all inquiries to our public 

affairs office at (202) 566-2391

or visit www.epa.gov/oig. 

The full report is at:

www.epa.gov/oig/reports/2015/ 

20150204-15-B-0074.pdf

EPA OIG Not Fully Compliant With OIG Policy on 

Time and Attendance Reporting 

 What We Found

The EPA OIG did not always comply with its policy 

for using IGEMS as its official internal system for 

recording time and attendance, including approval for 

leave and premium pay1 and other compensation. 

Some employees did not submit or have approved 

planned or actual timesheets in IGEMS when required under OIG Policy 323, 

OIG Time and Attendance Reporting Policy. 

The instances of noncompliance occurred because the time and attendance 

policy needs more clarity, and some OIG employees and managers do not view

IGEMS time reporting as a high priority. Without complete and accurate planned 

and actual timesheets in IGEMS, there is no basis for verifying that the data in 

the agency’s official payroll system (PeoplePlus) is accurate. The lack of planned 

timesheets can also result in using leave or increasing government obligation 

without proper authorization. In addition, IGEMS management reports may not 

always provide accurate and relevant information for time and attendance 

monitoring.

 Recommendations and Planned Corrective Action

We recommend that the Deputy Inspector General require employees and 

management to correct the instances of noncompliance identified and review 

future IGEMS records for appropriateness. We also recommend the review and 

revision of the OIG time and attendance reporting policy as necessary, and 

implementing controls to ensure that OIG employees and management comply 

with policy. The Deputy Inspector General agreed with our recommendations and 

provided corrective actions and planned completion dates to address all 

recommendations. 

 Noteworthy Achievements

The OIG’s Office of Mission Systems corrected agreed-to IGEMS report 

programming errors noted by our audit as soon as the errors were brought to 

their attention. 

 

1 Premium pay includes overtime and compensatory time. The EPA OIG conducted a separate review of the OIG’s compliance with 

OIG and EPA overtime policies.

Lack of complete and 

accurate timesheets 

can result in 

improper payments.

U.S. Environmental Protection Agency

Office of Inspector General

At a Glance
February 4, 2015

MEMORANDUM

SUBJECT: EPA OIG Not Fully Compliant With OIG Policy on Time and Attendance Reporting

Report No. 15-B-0074

FROM: Kevin Christensen, Assistant Inspector General

Office of Audit

TO: Charles Sheehan, Deputy Inspector General

As part of our continuing work to address the concerns raised as a result of the John C. Beale 

investigation, we began preliminary research of the U.S. Environmental Protection Agency (EPA) time 

and attendance process. As part of this work, we reviewed the EPA’s Office of Inspector General’s

(OIG’s) compliance with its policy for using the Inspector General Enterprise Management System

(IGEMS)—its official internal system for recording time and attendance. We briefed the Inspector 

General of our results, and he requested that we conduct an audit, accordingly. This report provides the 

results of that audit of the OIG and identifies issues that impact the OIG and require immediate 

attention. 

Action Required

During the exit conference, you provided corrective actions that addressed the recommendations and 

planned completion dates. The OIG must demonstrate that the proposed corrective actions are resolved 

before the report can be closed.

We will post this report to our website at http://www.epa.gov/oig.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C.20460

OFFICE OF

INSPECTOR GENERAL
EPA OIG Not Fully Compliant With OIG Policy 15-B-0074

on Time and Attendance Reporting

Table of Contents

Chapters

1 Introduction ........................................................................................................ 1

Purpose ........................................................................................................ 1

Background .................................................................................................. 1

Scope and Methodology ............................................................................... 2

2 Improvements Needed to Comply With

OIG Time and Attendance Policy ....................................................................... 4

IGEMS Planned Timesheets Not Submitted or Approved ............................. 4

IGEMS Actual Timesheets Not Submitted or Approved ................................ 5

OIG Time and Attendance Reporting Policy Needs More Clarity .................. 7

IGEMS Time and Attendance Recording Does Not Appear to Be

 Viewed as a High Priority .................................................................... 9

IGEMS Management Reports Need to Be Reevaluated................................ 9

Recommendations........................................................................................ 10

Exit Conference and Planned Corrective Action............................................ 11

Status of Recommendations and Potential Monetary Benefits ............................. 12

Appendix

A EPA OIG Distribution ....................................................................................... 13
15-B-0074 1

Chapter 1

Introduction

Purpose

We conducted this audit to determine whether the U.S. Environmental Protection 

Agency (EPA) Office of Inspector General (OIG) complied with its timekeeping 

policy for using the Inspector General Enterprise Management System (IGEMS)

as its official internal system for recording time and attendance. 

Background

On September 27, 2013, John C. Beale, a former Senior Policy Advisor with the 

EPA’s Office of Air and Radiation, plead guilty to a federal charge stemming 

from a long-running scheme in which he defrauded the government in salary 

payments and reimbursement for travel and other costs. From January 2000 to 

April 2013, Mr. Beale was absent from his duties at the EPA for about 21⁄2 years 

but was drawing a salary and benefits. A 2013 early warning report issued by the 

OIG

2

disclosed that one of the factors that facilitated Mr. Beale’s fraud was the 

agency’s lack of adequate controls over timekeeping. As a result, we initiated a 

review of the EPA’s and OIG’s internal controls over time and attendance. This is 

our report on an audit of the OIG’s time and attendance process. 

Prior Internal Review

As part of the annual Federal Managers’ Financial Integrity Act (FMFIA) review 

process for fiscal year (FY) 2009, the OIG’s Office of Chief of Staff (OCOS) 

conducted an internal review of timekeeping within the OIG and issued an 

internal memorandum of the results to the acting Inspector General on April 23, 

2010. Key IGEMS-related issues and OIG corrective actions were as follows: 

1) OIG Timekeeping Policy and Procedures Are Needed. The review found that 

while the agency’s Resource Management Directive Systems described

timekeeping responsibilities in connection with the agency’s payroll system—

PeoplePlus (PPL)—and the OIG had policies for specific purposes—such as 

flexible workplace program (telework), alternative work schedule, overtime, 

and compensatory time—the OIG did not have a policy for general 

timekeeping. As a result, OIG employees and management did not have 

documented resources to consult when trying to seek clarification on 

timekeeping issues. Consequently, OIG offices adopted varied practices to 

 

2 Early Warning Report: Internal Controls and Management Actions Concerning John C. Beale Pay Issues, 

EPA OIG Report No. 14-P-0036, issued December 11, 2013.
15-B-0074 2

complete IGEMS tasks, and request and approval for leave and flexiplace 

through IGEMS were not done consistently. The review suggested that the 

OIG establish an OIG timekeeping policy to ensure consistency, and that 

IGEMS be “...declared an official OIG timekeeping system and its use should 

be mandatory.”

2) Data Quality Improvements Are Needed. The review identified significant 

discrepancies between IGEMS and PPL data. The review suggested that the 

OIG issue a timekeeping policy to require timekeepers to compare IGEMS 

timesheets to PPL for each pay period and clear up discrepancies with 

employees before their supervisors approve timesheets.

In response to the review, the OIG issued Policy 323, OIG Time and Attendance 

Reporting, on July 7, 2011. The policy designated IGEMS as the official internal 

OIG system for recording time and requires all OIG employees to use the system 

to document requests for—and approval of—leave, premium pay,

3

travel 

compensatory time, credit hours, telework, change in the type of work schedule, 

and any material schedule changes. The policy also requires employees to enter 

their actual hours worked in IGEMS timesheets every pay period, supervisors to 

approve those timesheets, and timekeepers to reconcile those timesheets to PPL.

The OIG also issued Policy 004, OIG Procedures to Ensure Data Quality, on 

July 22, 2011. The policy identified IGEMS as a data system subject to the data 

quality policy requirements, and requires review and annual certification of the 

data quality as part of the FMFIA process. The OIG’s FYs 2010 and 2012 FMFIA 

assurance letters continued to identify IGEMS data quality and compliance with 

OIG and EPA timekeeping policies as areas needing improvement.

Scope and Methodology

We conducted this performance audit from June 14 to October 3, 2014, in 

accordance with the generally accepted government auditing standards issued by 

the Comptroller General of the United States. Those standards require that we 

plan and perform the audit to obtain sufficient, appropriate evidence to provide a 

reasonable basis for our findings and conclusions based on our audit objective. 

We believe that the evidence obtained provides a reasonable basis for our findings

and conclusions based on our audit objective.

To determine the OIG’s compliance with its policy requirements for using 

IGEMS as the official internal time and attendance recording system, we 

performed the following steps:

 Searched the OIG and agency intranets to identify applicable policies and 

reviewed those policies.

 

3 Premium Pay includes overtime and compensatory time. The EPA OIG conducted a separate review of the OIG’s

compliance with OIG and EPA overtime policies.
15-B-0074 3

 Reviewed applicable prior audit/review results, including the OIG’s 

internal timekeeping review completed in April 2010 and FMFIA 

assurance letters for FYs 2010 to 2014.

 Reviewed the OIG Management Action Plan Status Report as of the end 

of the second quarter of FY 2014.

 Met with OCOS to discuss prior review results.

 Interviewed selected managers and one timekeeper regarding the use of 

IGEMS planned timesheets for leave approval and other prior 

authorizations.

We judgmentally selected two pay periods (14 and 17) in FY 2014 for compliance 

testing. Pay period 14 was from March 23 to April 5, 2014; pay period 17 was 

from May 5 to 17, 2014. We reviewed employee documentation that was required 

to be submitted, in accordance with OIG Policy 323. We reviewed required 

documentation for 303 employees for pay period 14 and 301 employees for pay 

period 17 (a total 604 time and attendance records).

4 For each of these pay 

periods, we:

 Compared the official payroll records (PPL) in the agency’s accounting 

system—Compass Data Warehouse—to IGEMS records to identify 

discrepancies. 

 Determined whether the employees submitted planned and actual 

timesheets in IGEMS when required, in accordance with OIG policy.

 Reviewed IGEMS Employee Time TAAP (Time and Attendance 

Approval Processing) View report to identify planned and actual timesheet 

submittal and approval history.

 Reviewed IGEMS management reports to determine whether exceptions 

were adequately identified.

We also met with the Inspector General and OIG senior leaders to discuss 

timekeeping concerns and obtain their feedback on the issues identified. 

 

4 The total number of employee records on the OIG payroll was 606 (304 for pay period 14 and 302 for pay 

period 17). We excluded one employee from our calculations for each pay period because the employee was on 

detail outside of the OIG and did not have access to IGEMS. Therefore, we could not compare IGEMS to PPL.
15-B-0074 4

Chapter 2

Improvements Needed to Comply With 

OIG Time and Attendance Policy

EPA OIG did not always comply with its policy for using IGEMS as its official 

internal system for recording time and attendance in the IGEMS Time Planning

and Timesheet modules. As a result, some employees did not submit or have 

approved planned or actual timesheets in IGEMS when required under OIG 

Policy 323, OIG Time and Attendance Reporting. This occurred because:

 Policy 323 needs more clarity, especially regarding the purpose and 

importance of the Time Planning module as the OIG official mechanism 

to approve changes in employees’ schedules, such as leave and telework.

 Employees and management sometimes do not appear to view IGEMS 

time and attendance recording as a high priority. 

Without complete and accurate planned and actual timesheets in IGEMS, there is 

no basis for verifying that the data in the agency’s official payroll system—PPL—

is accurate. The lack of planned timesheets can also result in using leave without 

documenting proper authorization. Since IGEMS actual timesheets are used as the 

basis for determining the costs for the OIG’s projects and operations, the 

noncompliance will also result in inaccurate reporting of the costs for projects and 

operations. Further, IGEMS management reports may not always provide 

accurate and relevant information for time and attendance monitoring. 

IGEMS Planned Timesheets Not Submitted or Approved

Based on the two FY 2014 pay periods tested—pay periods 14 and 17—OIG 

employees did not always submit or have approved planned timesheets in IGEMS 

as required by OIG Policy 323. 

Section 2.1 of the policy, Roles and Responsibilities, requires IGEMS planned 

timesheet for all employees unless the employee is on a fixed 8-hour schedule or 

compressed work schedule5and leave is not anticipated. An IGEMS planned 

timesheet is required for employees on maxiflex6schedules and when requesting 

advance approval for leave (non-emergency situations), premium pay, travel 

 

5 A compressed work schedule is an 80-hour biweekly basic work requirement that is scheduled for fewer than 

10 workdays. The OIG offers employees a choice between a fixed 5-4/9 option (eight 9-hour days and one 8-hour 

day per pay period) or a fixed 4-10 option (four 10-hour days per week). 

6 Maxiflex is a flexible work schedule under which an employee may work fewer than 10 workdays in the biweekly 

period. A full-time employee must work 80 hours in the biweekly pay period, but, within the limits established for 

the organization, the employee may vary the number of hours worked on a given workday, as long as the employee 

works the core hours on workdays, and may vary the number of hours worked each week. 
15-B-0074 5

compensatory time, credit hours, telework, change in the type of work schedule, 

and any material schedule changes. Planned timesheets are required to be 

completed using the Time Planning module in IGEMS no later than the 

Wednesday prior to the start of the pay period being approved. Supervisors or 

team leaders with delegated authority are required to approve planned timesheets

in IGEMS no later than the Friday prior to the start of the pay period being 

approved.

The two pay periods tested included a total of 604 employee planned timesheets.

We found that 88 of the planned timesheets (14.6 percent) required to be 

submitted in accordance with the OIG policy were not approved in IGEMS as of 

June 14, 2014. This was more than 70 days after the due dates for pay period 14 

and more than 30 days for pay period 17. 

Of the 88 planned timesheets, employees never submitted a planned timesheet for 

the applicable pay period for 59 (9.8 percent) of the timesheets. The remaining 

29 timesheets were not approved either due to employees not submitting a final 

version after the earlier approved version was revised, supervisors returning the 

planned timesheets, or no action by the supervisor after the employee’s submittal. 

Table 1 summarizes.

Table 1: Results of IGEMS planned timesheet analysis

FY 2014

pay 

period

Total 

number of 

planned

timesheets

reviewed

No planned 

timesheet 

submitted

Earlier version

of timesheet

approved and

revised but not 

resubmitted or 

approved

Planned 

timesheet 

submitted 

but not 

approved

Total 

planned 

timesheets 

not 

approved

14 303 29 7 6 42

17 301 30 6 10 46

Total 604 59 13 16 88

Source: OIG’s analysis of planned timesheet data in IGEMS. 

IGEMS Actual Timesheets Not Submitted or Approved

For the two pay periods reviewed, OIG employees did not always submit or have 

approved actual timesheets in IGEMS as required under OIG Policy 323. We 

found that 35 of the 604 required employee timesheets (or 5.8 percent) were not 

approved in IGEMS as of June 14, 2014. Under the policy, timesheets were due 

on April 2 and May 14, 2014, for pay periods 14 and 17, respectively.

7

 

7 Exceptions apply for employees receiving Law Enforcement Availability Pay or Administratively Uncontrollable 

Overtime, as their timesheets were due on April 30 and June 11, 2014, respectively.
15-B-0074 6

Of the 35 timesheet exceptions, employees for 19 (or 3.1 percent) never submitted 

a timesheet for the applicable pay period. The remaining 16 did not have an 

approved timesheet for one of the following reasons:

 A revised timesheet was not submitted and/or approved although an 

earlier timesheet was approved.

 The supervisor returned the submitted timesheet and it was not 

resubmitted or approved.

 The supervisor did not approve the submitted timesheet.

Details are summarized in Table 2.

Table 2: Results of IGEMS actual timesheet analysis

FY 2014 

pay 

period

Total 

number of 

actual

timesheets

reviewed

No actual 

timesheet 

submitted

Earlier version 

of timesheet 

approved and

revised but not 

resubmitted or 

approved

Actual 

timesheet 

submitted 

but not 

approved

Total 

actual 

timesheets 

not 

approved

14 303 5 0 5 10

17 301 14 2 9 25

Total 604 19 2 14 35

Source: OIG’s analysis of actual timesheet data in IGEMS. 

Section 2.1.a(3) of OIG Policy 323 requires all employees—except those 

receiving Law Enforcement Availability Pay or Administratively Uncontrollable

Overtime—to enter their actual hours worked in IGEMS using the Timesheet

module no later than noon on the second Wednesday of the pay period. 

Employees receiving Law Enforcement Availability Pay or Administratively 

Uncontrollable Overtime are required to enter their time in the IGEMS Timesheet

module generally no later than noon the second Wednesday of the second pay 

period after the close of the period for which time is being entered. Employees

must also ensure that the correct number and type of hours are recorded in 

IGEMS and PPL.

Section 2.1.b(4) of the policy requires supervisors to confirm that the assigned 

timekeeper has verified that each employee’s submission of actual hours worked 

in the IGEMS timesheet module and PPL are in agreement with that approved in 

the time planning module, or that identified discrepancies are resolved, no later 

than the end of the following pay period. For employees receiving Law 

Enforcement Availability Pay or Administratively Uncontrollable Overtime, the 

supervisors are required to ensure that this reconciliation is completed by the end 

of the second pay period following the pay period for which time was worked, 

and that any necessary corrections are completed.
15-B-0074 7

OIG Time and Attendance Reporting Policy Needs More Clarity

OIG Policy 323 lacks clarity, especially regarding the intent and importance of 

the Time Planning module. 

According to the OIG policy, the IGEMS Time Planning module is the official 

mechanism for requests that require advance approval or denial by a supervisor.

However, the term Time Planning creates a misconception that the planned 

timesheet is for planned events only. Some managers believe that unplanned leave 

only needs to be reflected in the actual timesheets in IGEMS and it does not make 

sense to go back and amend the Time Planning module after the fact. Managers 

specifically identified the scenario where an employee would have unplanned and 

unscheduled sick leave at the end of the pay period—they believed that only the 

actual timesheet needed to be amended.

We do not agree. The Time Planning module is the official mechanism to 

document the approval or denial of all leave requests, not just planned leave 

requests. Prior to the adoption of IGEMS, if an employee took any type of leave 

(either planned or unplanned), the employee was required to submit a leave slip

(either paper form or through the agency’s Webforms system). Submitting a 

revised IGEMS Time Planning timesheet to reflect the unplanned leave would be 

equivalent to submitting a leave slip after the fact; it is necessary to formally 

document the request for leave by the employee and the approval of the leave 

request by the supervisor.

In addition, Section 2.1.a(1) of OIG Policy 323 requires approval for a major 

schedule change. A major schedule change is defined in Section 1.3 (g) as a 

change of 1 hour or more to a planned daily work schedule. As a result, taking 

unscheduled leave would require the planned timesheet to be updated and 

reapproved.

Further, Section 2.1.b(4) of OIG Policy 323 requires supervisors to confirm that 

timekeepers verified that each employee’s actual hours worked in IGEMS actual 

timesheet and PPL are in agreement with the approved IGEMS planned timesheet, 

or that identified discrepancies are resolved, no later than the end of the following 

pay period. If IGEMS planned timesheet is not revised to reflect the unplanned 

leave, it would not be in agreement with the IGEMS actual timesheet and PPL. 

Additionally, the planned timesheet is the official document that would be used 

for a supervisor to deny requests for leave by employees. This is critical because 

if an employee fails to report to work when leave is denied, all or part of the 

absence may be charged to Absence Without Leave (AWOL). 

The policy should be revised to provide clarification about the intent of the 

IGEMS Time Planning module and the procedures for handling unplanned events. 

Section 1.3.n of the policy states that the IGEMS Time Planning module is used 
15-B-0074 8

to report the “...planned schedule to supervisor for future pay periods. This

includes planned timesheets, annual/sick leave....” Section 2.1.a(1) states that 

advance approval via IGEMS time planning module is required when requesting 

for leave (except in emergency situations). However, the policy does not address 

how unplanned leave should be requested, approved or reported. The OIG may 

also consider renaming the IGEMS Time Planning module to better align with its 

true intent.

We also identified other areas in OIG Policy 323 that warrant further clarification 

to improve the OIG’s time and attendance process:

 Supervisor approval due date for IGEMS actual timesheet. The policy 

does not specifically provide a required supervisor approval date; it only 

provides a date to confirm reconciliation (i.e., mathematical exercise to 

ensure that there are no discrepancies in amount of time charged, leave 

taken, etc.,) between the planned and actual timesheets. 

 Scheduling “use or lose” leave. According to OCOS, OIG employees may 

carry over to the next leave year a maximum amount of accrued annual 

leave (240 hours for most employees). The leave exceeding that amount is 

“use or lose” leave that employees must “use” by the end of a leave year 

or they will “lose” (forfeit) it. OIG may consider restoring annual leave 

that was forfeited due to an exigency of the public business or sickness of 

the employee only if the annual leave was scheduled in writing in 

advance. In accordance with Office of Personnel Management 

requirements, each year, employees are required to submit in advance 

requests for leave related to use or lose three pay periods prior to the end 

of the year. To meet this requirement, OIG employees should schedule the

leave through the IGEMS Time Planning module. However, OIG Policy 

323 does not address the requesting and approval of use or lose leave or 

scheduling through the IGEMS Time Planning module. This is important 

because the OIG may consider restoring annual leave only if the annual 

leave was scheduled in writing before the deadline date. 

 Timesheet reconciliation. Section 2.1.b.(4) of the policy requires 

supervisors to confirm that timekeepers verified that each employee’s 

actual hours worked in the IGEMS actual timesheet and PPL are in 

agreement with the approved IGEMS planned timesheet. However, 

Section 2.1.d, where timekeeper responsibilities are defined, does not list 

reconciliation of the actual timesheet and PPL to the planned timesheet—

it only requires a reconciliation between the actual timesheet and PPL.

Consistency must be established throughout the policy. It should be noted 

that the reconciliation process does not alleviate a manager’s 

responsibility to review and approve time; ultimately, the manager needs
15-B-0074 9

to ensure that the actual timesheet and PPL reconcile to the planned 

timesheet. 

 Alternatives for IGEMS. While the policy requires leave, credit hours, 

telework, etc., to be requested and approved in IGEMS, some managers

believe there are alternative methods of approval. One manager stated that,

for his office, it is up to the individual supervisor/approver to set the 

expectation for his/her team. His team did not use planned timesheets for 

leave or telework approvals. Based on discussions with his colleagues, this 

manager believed he could continue to use Webforms for leave approval. 

Due to its infrequency, telework approval for his team was generally

granted verbally or through email and no documentation was maintained.

Another manager said that not submitting planned timesheets does not 

necessarily run the risk of unapproved leave because approvals can be 

accomplished via email. The OIG needs to better ensure that all employees 

and management understand and comply with the IGEMS requirements 

and that no alternative methods are allowed. 

IGEMS Time and Attendance Recording Does Not Appear to Be 

Viewed as a High Priority 

Employees and management do not appear to view IGEMS time and attendance 

recording as a high priority. OIG senior leadership was briefed on the time and 

attendance recording concerns on June 19, 2014, and was provided a listing of 

employees in their offices who did not comply with the policy. At that time, the 

Inspector General emphasized the importance for all OIG employees to comply 

with this policy and provide accurate and complete information into IGEMS. 

Nonetheless, as of September 23, 2014—or 3 months after the briefing—nine 

employees still did not have approved actual timesheets. Our final check on 

October 3, 2014, showed five employee remained noncompliant on actual 

timesheet approval for the two pay periods tested. 

One senior leader commented that the leader’s employees always have more work 

than people can do; therefore, the office cannot afford to have its staff spend an 

inordinate amount of valuable work time trying to keep up with what they 

considered to be duplicative—the Time Planning module in IGEMS. This may 

reflect the sentiment of other employees. Until everyone in the OIG understands

the requirement for complete IGEMS data, noncompliance may persist. 

IGEMS Management Reports Need to Be Reevaluated 

The IGEMS management reports may not always provide accurate and relevant 

information for time and attendance compliance monitoring. The audit disclosed 

programming errors and inconsistencies among IGEMS reports. For example, we 

noted seven employees who appeared to have approved their own timesheets 
15-B-0074 10

based on IGEMS reports. Upon follow-up, the OIG’s OMS found that there was a 

programming error in the IGEMS report; the employees had not approved their 

own timesheets. OMS corrected the error immediately.

While reviewing IGEMS management reports, we came across a report titled 

“advanced leave.” This report was more than 100 pages long. We asked OMS 

about the large number of employees taking advanced leave. OMS found a 

programming error and that the report was reading from an incorrect data field.

OMS subsequently determined that this report was not being used and, 

consequently, removed the report from the system.

We also noted some inconsistencies in the various IGEMS reports. For example, 

one employee was shown as not having submitted an IGEMS actual timesheet for 

the pay period ended April 5, 2014, in the Timesheet TAAP View report and 

Employee Timesheet by Pay Period report. However, the Employee Timesheet 

Approved in Pay Period report showed that the employee’s actual timesheet was 

submitted on April 17, 2014, and approved on May 1, 2014. OMS explained that 

the employee did not show up in the first two reports because she is no longer 

with the OIG. While we agree with the explanation provided by OMS, having

inconsistent information creates confusion.

Another inconsistency was in IGEMS management reports that provide the status 

of IGEMS actual timesheets. There are three reports available, each showing a 

different timesheet status—not submitted, not resubmitted or not approved. For 

pay period 14, we noted three employees who did not submit actual timesheets, 

but their names did not appear in any of the three IGEMS management reports

generated by the Product Line Director as an exception. The Product Line 

Director was given full access to the IGEMS management report module—the 

same access as the Inspector General. When we presented this issued to OMS, it

did not agree this was an issue. When OMS ran the same reports, the three 

employees correctly showed up on the OMS-generated reports as not submitted.

No further action was taken by OMS to research this anomaly.

Recommendations

We recommend that the Deputy Inspector General:

1. Require employees and management to correct the instances of 

noncompliance identified during the audit and review their IGEMS 

records for April 2014 forward to ensure that all planned and actual 

timesheets are submitted, approved and verified to match PPL in 

accordance with the policy requirement. 

2. Require OCOS to review and revise OIG policies to improve internal 

controls over time and attendance. 
15-B-0074 11

3. Require senior leadership to establish procedures to monitor compliance

with time and attendance policies and procedures. 

4. Require senior leadership to review IGEMS timekeeping reports to ensure 

that current reports are accurate (user and/or programming issues) and 

relevant, and meet the needs for compliance monitoring. Identify as a high 

priority all modifications that need to be made to IGEMS and allocate 

resources to have modifications completed.

Exit Conference and Planned Corrective Action

We conducted a preliminary exit conference with the Deputy Inspector General

on July 21, 2014. On July 23, 2014, we issued finding outlines to the Deputy 

Inspector General who, in turn, distributed the finding outlines to OIG senior 

leadership for feedback. 

We received comments and suggestions from senior leadership between July 25 

and August 18, 2014. We reviewed the comments and suggestions and made 

changes to this report as we considered necessary. We did not issue revised 

finding outlines. Instead, the results were incorporated into this final report.

On November 18, 2014, we conducted a final exit conference with the Deputy 

Inspector General to discuss our recommendations and his proposed corrective 

actions. The Deputy Inspector General agreed with our recommendations and 

provided proposed corrective actions and completion dates for all 

recommendations. We agree with the proposed actions and consider the 

recommendations open with corrective actions ongoing.
15-B-0074 12

Status of Recommendations and 

Potential Monetary Benefits

RECOMMENDATIONS

POTENTIAL MONETARY 

BENEFITS (in $000s)

Rec. 

No.

Page 

No. Subject Status1 Action Official

Planned 

Completion 

Date

Claimed 

Amount

Agreed-To 

Amount

1 10 Require employees and management to correct the 

instances of noncompliance identified during the 

audit and review their IGEMS records for April 

2014 forward to ensure that all planned and actual 

timesheets are submitted, approved and verified to 

match PPL in accordance with the policy 

requirement. 

O Deputy Inspector General 3/31/15

2 10 Require OCOS to review and revise OIG policies to 

improve internal controls for time and attendance.

O Deputy Inspector General 9/30/15

3 11 Require senior leadership to establish procedures 

to monitor compliance with time and attendance 

policies and procedures.

O Deputy Inspector General 9/30/15

4 11 Require senior leadership to review IGEMS 

timekeeping reports to ensure that current reports 

are accurate (user and/or programming issues) and

relevant, and meet the needs for compliance 

monitoring. Identify as a high priority all 

modifications that need to be made to IGEMS and 

allocate resources to have modifications 

completed.

O Deputy Inspector General 9/30/15

1 O = Recommendation is open with agreed-to corrective actions pending. 

C = Recommendation is closed with all agreed-to actions completed. 

U = Recommendation is unresolved with resolution efforts in progress.
15-B-0074 13

Appendix A

EPA OIG Distribution

Inspector General

Deputy Inspector General

Counsel to the Inspector General

Chief of Staff, Office of Inspector General

Assistant Inspector General for Investigations

Assistant Inspector General for Mission Systems

Assistant Inspector General for Program Evaluation

Deputy Assistant Inspector General for Congressional and Public Affairs